Employee Candidate Data Protection Statement
Effective date: 25 May 2018
European Union general data protection regulation ((EU) 2016/679) compliant version
Siili Solutions Oyj ("Siili", also "we", "us", "our"; Finnish Business ID 1979903-5) places the highest value on protecting your personal data. Siili is the data controller of your personal data in the context described in this Employee Candidate Data Protection Statement ("Statement"). As data controller Siili is responsible for your personal data processing and defines the purposes and means for the processing of your personal data. Please note, that other companies belonging to the same group of companies with us (i.e. affiliates of Siili) do not operate under this Statement – they take independent decisions concerning their data protection information documentation and practices as necessary.
This Statement explains our commitment to keep your personal data ("Employee Candidate Data") confidential and secure. Further, the Statement informs you on the Employee Candidate Data processing practices related to our recruitment process activities ("Recruitment Process"). Employee Candidate Data processing in Siili online Recruitment Process tools, used e.g. for publishing job advertisements and receiving job applications, belongs to the scope of this Statement.
Additional and more detailed data protection information applicable to Employee Candidate Data is available in:
- Siili Employee Candidate Data Protection Description ("Description", all references to this Statement include also the contents of the Description unless otherwise stated case by case).
In case of possible discrepancy, the information provided in the Description prevails the information presented in this Statement.
Siili processes your Employee Candidate Data always in accordance with all applicable laws.
Please read this Statement carefully before participating in the Recruitment Process. By participating in the Recruitment Process and/or by submitting (directly or indirectly) your Employee Candidate Data to us, you express your understanding to the processing of your Employee Candidate Data in accordance with this Statement. Otherwise, we expect that you will discontinue participating in the Recruitment Process and not to provide or cease providing us with your Employee Candidate Data. Please note, that absence of your Employee Candidate Data might prevent us from taking you into account in the Recruitment Process.
Your Consent to Siili
Your consent to Employee Candidate Data processing by us covers all collecting (also from any third parties or third party sources relevant for Recruitment Process) and processing activities for all Employee Candidate Data obtained in connection to the Recruitment Process for the purposes defined in this Statement.
You submit your consent to us by providing us with your Employee Candidate Data either by continuing the use of our online Recruitment Process tool or by contacting us by other means, e.g. by sending us an e-mail or a letter.
Although we do not on our initiative generally collect or process Sensitive Employee Candidate Data (as described below), your consent would cover also all collection and processing of Sensitive Employee Candidate Data should the case that require. For instance, if you independently, without our general or specific request, provide us with any Sensitive Employee Candidate Data (e.g. by enclosing your photo or any health information as part of your application or curriculum vitae), you will be deemed to have provided us with your separate intentional consent for Sensitive Employee Candidate data processing for the purposes described in this Statement.
You have the right to withdraw your consent at any time. To do so, please contact us with the email dataprotection(at)siili.com.
Please note that the withdrawal of your consent will immediately prevent us from taking you into account in the Recruitment Process.
Lawfulness of Processing of Your Employee Candidate Data
Processing of your Employee Candidate Data by us is based on:
- Consent(s) received from you and third parties (as may be required by the law); and
- Obligations and rights of Siili based on mandatory laws – such laws include but are not limited to labor, data protection and non-discrimination laws as well as penal codes.
Siili Data Collection Methods
Participating in the Recruitment Process requires you to personally submit to us certain Employee Candidate Data. Besides the utilization of our online Employee Candidate Data collection methods, depending on the Recruitment Process, we may also collect all or certain Employee Candidate Data from you in a phone call, job interview or with other non-computerized means common in Recruitment Process.
Additionally, but always informing you and obtaining your consent in advance, we may collect your Employee Candidate Data from any public sources, third parties, our own employees and/or other persons providing services for us. We may also collect Employee Candidate Data from personality and aptitude assessments you might be required to participate during Recruitment Process. By providing us your consent as described above, you consent also to such data collection from third parties.
Employee Candidate Data Siili Collects and Processes
Basic Employee Candidate Data typically collected and processed by us consists mostly of your name, contact details, work experience, education, skills, references, curriculum vitae and letter of application. When providing us with information about a third party individual (such as in form of references or recommendations), you are responsible for ensuring that you have attained all such third party consents possibly required for providing us with the information as stipulated by the law.
In addition, we may collect other types of Employee Candidate Data necessary for the Recruitment Process in question. Detailed information concerning the types and processing of Employee Candidate Data is available in the Description.
We do not generally collect or process any Employee Candidate Data belonging to special categories ("Sensitive Employee Candidate Data" such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or data concerning health or sex life). However, as the case may be, we may occasionally need to collect and process some Sensitive Employee Candidate Data about you, if it is necessary to ensure the compliance with any mandatory legal requirement or e.g. to assess your suitability as part of the Recruitment Process.
Furthermore, if you participate in the Recruitment Process via our online Recruitment Process tool, we may automatically track certain personal data concerning you, such as the internet protocol (IP) address, the source of visit and the type of your web browser even prior to explicitly requesting any of your Employee Candidate Data described above.
Siili Purposes of Processing
We process your Employee Candidate Data mainly in the Recruitment Process including receiving job applications, arranging and concluding job interviews, assessing employment potential, and any other actions necessary for the conclusion of the Recruitment Process. Therefore, the primary purpose of processing of your Employee Candidate Data is:
- Fulfilling Siili open job positions.
We also process Employee Candidate Data for the following purposes:
- Collecting and maintaining an employee candidate pool for future purposes;
- Collecting feedback from employee candidates; and
- Ensuring your and our rights and our compliance with any other legislation applicable to the Recruitment Process.
Detailed information about our purposes of uses of Employee Candidate Data is available in the Description.
Your Employee Candidate Data will not be used for direct marketing or for any other purpose than those described above in this Statement and in the Description.
Retention of Your Employee Candidate Data
Generally, we retain your Employee Candidate Data no longer than twenty-four (24) months from the earlier of:
- First Recruitment Process decision (whether positive or negative) where your Employee Candidate Data is used; or
- Collection of Employee Candidate Data (in case no Recruitment Process decision concerning you is made);
Notwithstanding the above, if you withdraw your consent for Employee Candidate Data processing, your Employee Candidate Data shall be archived and used only for ensuring your and our rights and our compliance with any other legislation applicable to the Recruitment Process. In this case the retention (in archive but not in any operational IT systems) shall not exceed twenty-four (24) months from the withdrawal of your consent.
Notwithstanding the above, the retention may be extended due to existing or imminent need of Siili to establish, exercise or defend itself against legal claims.
Disclosures and Transfers of Employee Candidate Data
We do not generally disclose any Employee Candidate Data to be independently used by other data controllers outside Siili unless required by mandatory law (such as to tax and other authorities).
We may transfer your Employee Candidate Data to Siili affiliate companies or to third parties (e.g. subcontractors) who process Employee Candidate Data on behalf of us for the purposes described in this Statement. In this way, we do not release the Employee Candidate Data from our effective control.
As we operate internationally, due to necessary technical and practical requirements your Employee Candidate Data may be processed by Siili affiliate companies or subcontractors located outside the European Union or European Economic Area (incl. Switzerland). Hence, countries to which your Employee Candidate Data may be sent to or accessed from may have a data protection standard differing from the country in which you are situated. In all such Employee Candidate Data transfer situations, the processing of Employee Candidate Data shall be in accordance with applicable legislations (e.g. justified by EU Commission standard contractual clauses) and our data processing policies and instructions.
We may also need to share your Employee Candidate Data with a purchaser or potential purchaser of our business. Such sharing does not occur regularly, but should it be necessary, we will share only smallest possible amount of your Employee Candidate Data and always in the limits of applicable legislation.
We may provide aggregate statistics about our employee candidates and the Recruitment Process to reputable third parties, but these statistics are anonymized and will not include your Employee Candidate Data.
Transmission of information in the internet is not completely secure. Therefore, we cannot fully guarantee the security of your Employee Candidate Data transmitted to us. All such transmissions are at your own risk. Once we has received your Employee Candidate Data, strict procedures and security features will be used to prevent unauthorized and illegal access, alteration and denial of use of your Employee Candidate Data.
We may occasionally place information on your computer which allows us to recognize your computer. This information is commonly known as a “cookie”. Typically, cookies enable collection of certain information regarding your computer, including your IP address, your computer’s operating system, your browser type and the address of any referring sites. Cookies are intended to improve availability and quality of the Recruitment Process. A separate Cookie Statement explains the cookies in detail (references to Statement above and below include also the contents of the Cookie Statement unless otherwise stated case by case). In case of possible discrepancy, the information provided in the Cookie Statement prevails over information of this Statement and the Description.
Your Rights Concerning Data Processing
At any time, you have the right to:
- Gain access to your Employee Candidate Data;
- Verify the accuracy of your Employee Candidate Data and at your request, have your incomplete, inaccurate or outdated Employee Candidate Data modified or erased;
- Under certain circumstances, be forgotten by us;
- Under certain circumstances, have the processing of your Employee Candidate Data restricted;
- Receive your Employee Candidate Data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller; and
- Lodge a complaint with a supervisory authority (Finnish Data Protection Ombudsman).
Also, at any time, you have the right to:
- Withdraw your consent to processing of your Employee Candidate Data.
Please note that the withdrawal of your consent will immediately prevent us from taking you into account in the Recruitment Process.
You may contact us to the contact information provided below or in the Description in order to use your rights. For more detailed description of your rights, please refer to the Description.
Our information sources related to the Recruitment Process may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to of from any of these websites, please note that these websites are separate from our websites and do not operate under this Statement or any other of our data protection practices, but have their own privacy policies, data protection statements or similar announcements. We do not accept any responsibility or liability for these policies, statements and announcements or the lack of them or your use of such websites. Please check these policies, statements and/or any other data protection documents before you submit any Employee Candidate Data to these websites.
New Versions of This Statement
We may change or amend this Statement as necessary and recommends therefore, that you revisit this Statement regularly.
Siili Contact Information
If you want to contact us in data protection related matters (concerning Recruitment Process or in general), please send us e-mail at dataprotection [at] siili.com.
Additional Recruitment Process specific data protection contact information (including mailing address and telephone numbers) are available in the Description.